Implement a written program which meets the requirements of the Hazard Communication Standard for employees handling or otherwise exposed to chemicals, including drugs that represent a health
hazard to employees. The written program must provide for worker training, warning labels, and access to Safety Data
Sheets (SDSs). Employees must be informed of the requirements of the Hazard Communication Standard including:

Any operation/procedure in their work area where drugs that present a hazard are present.

The location and availability of the written hazard communication program.

Any operations or procedure in their work area where other HD's are present.

The location and availability of any other plan regarding HD's.

The HCS only applies to pharmaceuticals that the drug manufacturer has determined to
be hazardous and that are known to be present in the workplace in such a manner that employees are exposed under normal conditions
of use or in a foreseeable emergency
[OSHA Interpretation Letter, (1994, March 3)].

Chemicals with any of the following characteristics are considered hazardous: carcinogenic, corrosive, toxic or
highly toxic, irritating, sensitizing, or target organ effecting. [Hazard Communication Standard Appendix A and chemicals listed in
29 CFR 1910.1000 Table Z-2].

Both human and animal data are to be used in this determination. The Hazard Communication Standard, Appendix B lists sources of toxicity
information.

All personnel involved in any aspect of the handling of covered hazardous drugs (physicians, nurses, pharmacists, housekeepers,
employees involved in receiving, transport or storage) must receive information and training to apprise them of the hazards presented
by hazardous drugs in the work area, [OSHA Technical Manual Part V, Section A, #2] including the
following:

Methods and observations that may be used to detect the presence or release of an HCS-covered hazardous drug in
the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of covered
HD's being released, etc.).

The physical and health hazards of the covered HD's in the work area.

The measures employees can take to protect themselves from these hazards. This includes specific procedures that the employer
has implemented to protect the employees from exposure to such drugs, such as identification of covered drugs and those to be
handled as hazardous, appropriate work practices, emergency procedures (for spills or employee exposure).

Personal protective equipment, and the details of the hazard communication program developed by the employer, including an
explanation of the labeling system and the SDS, and how employees can obtain and use the appropriate hazard information.

Any workplace exposure record created in connection with HD handling shall be kept, transferred, and made available for at least
30 years and medical records shall be kept for the duration of employment plus 30 years in accordance with the Access to Employee
Exposure and Medical Records Standard
[29 CFR 1910.1020].

Other Recommended Good Work Practice:

Develop, implement and maintain a written hazardous drug safety and health plan to protect those employees who handle or are
otherwise exposed to drugs that pose a health hazard to them.

PPE: OSHA 29 CFR 1910.132 requires the employer to assess potential hazards and then select and ensure the use of appropriate PPE to protect employees from
hazardous chemicals, including hazardous drugs as defined by the Hazard Communication Standard.

Eye and Face Protection: OSHA 29 CFR 1910.133 requires the use of
chemical-barrier face and eye protection whenever splashes, sprays, or aerosols of HD's may be generated that could result in eye,
nose, or mouth contamination.

The OSHA Technical Manual,
describes the effective use of gloves and gowns when working with Hazardous Drugs
[OSHA Technical Manual Part V, Section B, #6].

The thickness of the gloves used in handling hazardous drugs is more important than the type of material. The best results have
been seen with latex gloves.

Double gloving is recommended because all gloves are permeable to some extent, and their permeability increases with time.

When double gloving, one glove should be placed under the gown cuff and one over. The glove-gown interface should be such that no
skin on the arm or wrist is exposed.

To limit transfer of contamination from the BSC into the work area, the outer gloves should be removed after each task or batch,
and should be placed in "zipper" - closure plastic bags or other sealable containers for disposal.

Gloves should be changed regularly (hourly) or immediately if they are torn, punctured, or contaminated with a spill.

Thicker, longer, latex gloves that cover the gown cuff are recommend with minimal or no powder since the powder may absorb
contamination.

The worker should wear a protective disposable gown made of lint-free, low-permeability fabric, with a solid front,
long sleeves and tight-fitting elastic or knit cuffs.

Hand washing: Hands should be washed before gloves are put on, and after they are removed.

Restricted Drug Preparation Room

Restricted Preparation areas: OSHA and the American Society of Hospital Pharmacists recommend that hazardous drug preparation be performed in a
restricted area, with signs restricting the access of unauthorized personnel prominently displayed
(OSHA Technical Manual Part V, Section B, #1).

Restricted Activities: Smoking, drinking, applying cosmetics, or eating where
hazardous drugs are prepared, stored, or used, increases the chance of exposure, and should be prohibited
(OSHA Technical Manual Part V, Section B, #1).

Hazardous Drugs should be prepared by pharmacists, not by nurses or physicians without proper PPE and engineering controls. The risk of exposure to hazardous drugs through inhalation or direct skin contact, is present in procedures such as:

Transferring hazardous drugs from one container to another, reconstituting or manipulating them.

Withdrawal of needles from drug vials.

Expulsion of air from a drug-filled syringe.

Expelling air from syringes should be done in the biological safety cabinet, not by the health care worker giving the injection.

Sharps Handling: OSHA and the American Society of Hospital Pharmacists (ASHP) recommend that all syringes and needles used in the course of preparation be placed in "sharps" containers for disposal without being crushed, clipped or capped.

Priming of tubing for hazardous drugs: The OSHA Technical Manual recommends that drug administration sets be attached and primed within the BSC prior to addition of the drug. This eliminates the need to prime the set in a less well-controlled environment. It also states that the priming should be done with non-drug containing solution or that a back-flow closed system be used.

Labeling Practices: In addition to standard pharmacy labeling practices, all syringes and IV bags containing hazardous drugs should be labeled with a warning label such as: Special
Handling/Disposal Precautions.

Ribavirin an antiviral drug used to treat some infants and young children with lower respiratory syncytial
virus (RSV) infections. This drug is aerosolized to a respirable size of approximately 1.3 microns and is usually administered to
the patient in an oxygen tent or face mask. This is when exposure can occur.

Thick, leak-proof plastic bags, colored differently from other hospital trash bags, should be used for routine collection of
discarded gloves, gowns and other disposable material, and labeled as Hazardous Drug-related wastes.

The Technical Chapter suggests the waste bag should be kept inside a covered waste container clearly labeled "Hazardous
Drug WASTE ONLY." At least one such receptacle should be located in every area where the drugs are prepared or administered.
Waste should not be moved from one area to another. The bag should be sealed when filled and the covered waste container taped.

The use of properly labeled, sealed and covered disposal containers, handled by trained and protected personnel, as required under
the Bloodborne Pathogens Standard if such items are contaminated with blood or other potentially infectious materials.

Hazardous drug-related wastes should be disposed of according to EPA, state and local regulations for hazardous waste.
This disposal can occur at either an incinerator or a licensed sanitary landfill for toxic wastes, as appropriate. Commercial waste
disposal is performed by a licensed company. While awaiting removal, the waste should be held in a secure area in covered, labeled
drums with plastic liners.

Storage of Hazardous Drugs: Access to areas where Hazardous Drugs are prepared
and stored is limited to authorized personnel only, with signs restricting entry.

Storage Area for Hazardous Drugs: Bins or shelves where Hazardous Drugs are stored
should be designed to prevent breakage and to limit contamination in the event of leakage, with bins with barrier fronts, or other
design features that reduce the chance of drug containers falling to the floor.

Warning labels should be applied to all HD containers, shelves, and bins, where these containers are stored.

The American Society of Hospital Pharmacists (ASHP) recommends hazardous drugs requiring refrigeration be stored separately from
non-hazardous drugs in individual bins designed to prevent breakage and contain leakage.

Some employees develop latex allergy from exposure to latex in products like latex gloves. This can cause reactions from irritant contact dermatitis, and allergic contact sensitivity to immediate possible life threatening sensitivity.

Potential Hazard

Developing latex allergies from exposure to latex products.

Possible Solutions

OSHA requires:

Bloodborne Pathogen Standard states, The employer shall ensure that appropriate personal protective equipment
in the appropriate sizes is readily accessible at the worksite or is issued to employees. Hypoallergenic gloves, glove liners,
powderless gloves, or other similar alternatives shall be readily accessible to those employees who are allergic to the gloves
normally provided
[29 CFR 1910.1030(d)(3)(iii)].

Please note that hypoallergenic gloves, glove liners, or powderless gloves are not to be assumed to be non-latex
or latex free.

Other Recommended Good Practices:

Research indicates the thickness of the gloves used in handling hazardous drugs is more important than the type of material used.
Non latex gloves and other latex free products are available.